1	7. Newdow felt like an "outsider" when he heard the
2	prayer. Complaint, 1 30.
3	8. Newdow is a "minister" of a "religious faith" that
4	specifically denies the existence of God and the "veracity" of
5	Christianity. Complaint, H 30.
6	9. Newdow alleges he watched the inauguration on
7	television. Complaint 1 28, presumably from his home in
8	California.
9	10. Reverend Graham received no compensation from anyone,
10	including the federal government and the Committee, for
11	delivering the invocation, nor was he reimbursed for his travel,
12	meals, or lodging expenses incurred to participate in the
13	inauguration. Graham declaration, If 5.
14	III. SUMMARY OF ARGUMENT
15	Plaintiff Newdow lacks Article III standing because he
16	suffered no concrete, particularized injury when he watched the
17	Rev. Graham say a prayer at President Bush's inauguration on
18	January 20, 2001. His claim that he will be harmed by future
19	inaugural speeches is entirely speculative and insufficient to
20	entitle him to injunctive relief.
21	Plaintiff also lacks prudential standing to challenge the
22	recitation of a prayer reflecting Christian values because he
23	cannot effectively protect the rights of theistic non-Christians
24	who may approve of prayers that refer to God.
25	///
27  (con't) have "the ability to regulate the content of [the student's graduation] speech ...a hallmark of state
28  involvement....Adier, at 1337.